 |
FEI
|
1.1 The Federation of the Electronics Industry is pleased to comment on this latest Government consultation on the implementation of radio spectrum pricing. FEI notes that the proposals continue the process started in previous years’ consultation documents, which FEI and its individual members responded to in detail. FEI members will continue to participate in this process and will respond to the individual sector Appendices where appropriate. In particular we look forward to seeing the proposals relating to Fixed satellite earth stations, Fixed Wireless Access and Broadcasting.
2.1 FEI notes that there are significant errors in the assumptions made in Section 6 of the Smith and NERA Report and is concerned that the Agency has generally accepted the report’s recommendations without noticing these errors. The Agency has already been notified of the errors and their effect of raising significantly the reference prices quoted in the Report.
3.1 As mentioned in previous responses, the phasing in period of increased fees needs to be sufficiently long to enable users to plan for the effect of the changes in fee levels and to respond accordingly. FEI are pleased to note that our support for a 4-year phase-in period as the minimum that is reasonable has been confirmed for Public Mobile Operators and Common Base Stations.
3.2 FEI are also pleased that the suggestion to facilitate long-term business planning (by giving clear indications of the likely plans for spectrum pricing beyond the initial phasing in periods) have been addressed. We support the consideration being given by the Agency and by SMAG to quantify the effectiveness of spectrum pricing and to continue discussing congestion factors and fee modifiers.
3.3 FEI note that the importance of spectrum, in terms of the economic benefit to the UK, is still quoted using figures which are now 3 years out of date. We urge the Agency to complete, as soon as possible, a new economic impact study to enable effective promotion of the benefits of the spectrum resource to the knowledge driven economy.
3.4 Finally, FEI also note the side effect of the proposals will be a considerable increase in fee income to the Treasury, over and above the present cost of running the Agency, on which licence fees were previously based. We still believe that it is important that this income be applied to promotion of the defined aims and are disappointed that there is no indication of this in the third stage document. A particular example might be increased funding for UK research in universities or through joint industrial/academic programmes such as the LINK PCP. Research areas could include methods for measuring spectral efficiency, spectrum sharing technology, RF health and safety and support for the disabled. Funding of such research will help to keep the UK at the forefront of development of innovative and beneficial services and commercial exploitation of our expertise in European and world markets.
|
